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BACARDI PRIVACY POLICY
MARCH 4, 2013

INFORMATION ABOUT US

Bacardi Global Brand Limited is registered in England & Wales under company number 3651489 with a registered office and main trading address at 28 Dorset Square, London, NW1 6QG, United Kingdom (“we or us” or “BGB”). Our VAT number is GB 222 2530 16.

For the purpose of the Data Protection Act 1998 (the “Act”), BGB will be the data controller responsible for any personal information you may submit on this Site. However, in certain circumstances, other companies in the Bacardi Group of companies, or other third parties, may become data controllers of that information. Please see Section 7 of this Privacy Policy below for more information about those companies.

We are committed to protecting and respecting your privacy. This Privacy Policy (together with the Bacardi Terms and Conditions of Website Use and our Cookie Policy and any other documents referred to in them govern our use of information gathered about you. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Although we are committed to maintaining your confidence and trust in all of our activities with you, this Privacy Policy does not govern our collection or use of data about you through channels other than our Sites (as defined in Section 3 below).

Please exit this Site immediately if you do not accept this Privacy Policy, are not of a Legal Drinking Age (as defined in the Bacardi Terms and Conditions of Website Use) in the country or other territory in which you are located, or are accessing our Sites in a country or other territory where use of our Site is not permitted.

SOCIAL RESPONSIBILITY

We are extremely proud of our high quality brands, products and marketing. That pride goes hand in hand with a deep sense of responsibility and respect for the global communities that we serve and the individual consumers who enjoy our products. As part of our commitment to responsible marketing, we comply with the social responsibility policies established by DISCUS — the Distilled Spirits Council for the United States and spiritsEUROPE — the European representative body for producers of spirit drinks, which set out the principles we maintain in all of our sales and marketing activities, including advertising and promotional programmes.

DATA WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

Information that you provide by filling in forms on websites operated by the companies within the Bacardi group of companies (including but not limited to BGB, Bacardi & Company Limited, their affiliates, subsidiaries, their ultimate holding company and its subsidiaries as defined in section 1159 of the UK Companies Act 2006 (together, the “Group Companies”)) (those sites are referred to in this Privacy Policy as “our Sites”). This includes information provided at the time of registering to use any of our Sites, subscribing to any services offered on our Sites including but not limited to email mailing lists, competitions, games, interactive services, posting material or requesting further services. That information will usually include your name or a username and your email address, though from time to time some of the services we provide may mean that we ask you for more information. We may also ask you for information when you enter a competition or promotion sponsored by a Group Company, and when you report a problem with any of our Sites;

The correct country or other territory in which you are located or are accessing our Sites and your correct date of birth, which we require that you submit accurately to ensure that you do not access our Sites if you are not of Legal Drinking Age in the country or other territory in which you are located or are accessing our Sites;

If you contact us, we may keep a record of that correspondence;

A Group Company may also ask you to complete surveys to be used for research purposes, although you do not have to respond to them;

Details of any transactions you carry out through any of our Sites and of the fulfilment of any orders by you;

Details of your visits to our Sites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access; and

Any information we may collect about you from third party or off-line sources, and which we may combine with information collected via our Sites.

IP ADDRESSES AND COOKIES

We may collect information about your computer (including, where available, your IP address, operating system and browser type) for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual. Our Internet servers may also keep track of the number of visitors to our Sites, the pages they visited and how long they stayed. None of this information includes any personal information about you.

For the same reason, we may obtain information about your general Internet usage by using a “cookie” file which is stored on the hard drive of your computer. For more information please see our Cookie Policy.

WHERE WE STORE YOUR PERSONAL DATA

We are a global company with a long history of providing our products to responsible consumers all over the world. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") including but not limited to the USA. Data we collect may also be processed by staff operating outside the EEA who work with us or for us, or for one of our affiliated companies, suppliers or service providers. Such staff may be engaged in, among other things, the management of our customer records, the fulfilment of email and other marketing campaigns, analysis of visitors to our Sites, distribution of newsletters, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take reasonable physical, administrative, and technical steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

The information you provide to us is stored on our secure servers. Possible payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a user identification code, password or any other piece of information as a part of a registration scheme or a security procedure to enable you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. In particular, you should not share your password with anyone who is not of Legal Drinking Age in the country or other territory in which you are located or are accessing our Sites or to anyone in a country or other territory where use of our Sites is not permitted.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to any of our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

OUR USE OF YOUR INFORMATION

We use information held about you in the following ways:

To ensure that content from our Sites is presented in the most effective manner for you and for your computer;

To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;

To allow you to participate in interactive features of our service when you choose to do so;

To notify you about changes to our service; and

We also reserve the right to share information with other organisations in the following situations:

As permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of Bacardi’s Terms and Conditions or Website Use or other agreements, or as required by law;

When we have your consent to do so;

When we need to share information to provide any product or service you have requested; and

When we share information with the organisations described in Section 7 of this Privacy Policy.

If you are an existing customer, we will only contact you by appropriate electronic means with information about goods and services similar to those which were the subject of a previous sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.

DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information amongst the Group Companies. In certain circumstances, those Group Companies who receive your personal information may decide to use your information for the purposes described in this Privacy Policy. In so doing, they may become the responsible data controller of your information for those uses, in place of BGB, in accordance with applicable data protection or other privacy laws. Those Group Companies may be located in the jurisdiction or territory in which you reside, and their use of your personal information may be subject to the data protection or privacy laws which apply in that jurisdiction. The use of your information by those Group Companies will still be subject to the provisions of this Privacy Policy. For details about the Group Companies active in your country and information about how to contact them, please ask us by writing to webmaster@bacardi.com or to

We may also disclose your personal information to the following selected third parties:

Our advertising and promotional agencies and consultants and those organisations selected by us to carry out marketing campaigns or email mailings on our behalf, or analyse or evaluate our data collection process or customer service fulfilment;

Unaffiliated service providers with whom the Group Companies may subcontract, including advertising and promotional agencies, website hosting companies, fulfilment companies and other third party service providers;

Unaffiliated partner organisations with whom we may carry out joint campaigns or events, or operate the Site on which information about you is collected. In certain circumstances, those organisations may be joint data controllers of your information, together with BGB. The Site page on which you submit your information will tell you when this is the case and you have the right to opt out upon your simple request;

The prospective seller or buyer (other than a Group Company) of any Group Company’s business or assets, including where a Group Company or substantially all of its assets is acquired by a third party other than another Group Company, in which case personal data held by it about its customers will be one of the transferred assets;

If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or in order to enforce or apply the Bacardi Global User Terms and Conditions and other agreements; or to protect the rights, property, or safety of the Group Companies, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

YOUR RIGHTS

The Data Protection Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. We will inform you (before collecting your data) if we intend to use your data for marketing purposes or if we intend to disclose your information to any third party for marketing purposes. You can exercise your right to prevent such processing by ticking the relevant boxes on the forms we use to collect your data. If you at any time decide that you do not want to be contacted for any purpose or if you would like to obtain a copy of the personal information about you gathered by our Sites or correct or delete such information from our Sites’ databases, you can contact us by writing to our Digital Director at: webmaster@bacardi.com.

Our Sites may, from time to time, contain links to and from the websites of our partner networks, creative partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

VARIATIONS

We may revise this Privacy Policy at any time by amending this page. When we do, we will post the change(s) on the Site. Each time you use our Sites, the then-current version of the Privacy Policy will apply. Accordingly, when you use our Sites, you should check the date of the Privacy Policy (which appears at the top right hand corner) and review any changes since the last version.

CHILDREN

Our Sites are designed to appeal to adults. We do not knowingly solicit any information from children nor do we knowingly market or otherwise target our Sites or its products or services to children. If we become aware that a visitor to our Sites is under the Legal Drinking Age in the country or other territory in which he or she is located at the relevant time and has registered without verifiable parental consent, we will remove his or her personal information from our files.

CONTACT

Questions, comments and requests regarding this Privacy Policy, or our privacy practices in general, are welcomed and should be addressed to: